Leadership training receipts not taxable as per India – Portuguese DTAA

Sandvik AB Vs ACIT (International Taxation) (ITAT Pune) ITAT Pune held that leadership training receipts is not chargeable to tax in the light of Article 12(4)(b) of DTAA between India and Portuguese Facts- The assessee received a sum of Rs.17,43,73,176/- named as Management Support fees pursuant to an Agreement with SAPL, its Indian entity, for rendering services in the nature of Commercial, Management, Marketing and Administrative. It was claimed that this amount was not chargeable to tax because of the Double Taxation Avoidance Agreement (DTAA) between India and Sweden read with the DTAA be...